Frequently-Asked Question FAQ #244

FAQ-244: "Should" in standards

Question: What is the OPS position with regard to implementation of "should" statements in industry standards that are invoked by the rule?

Answer: OPS expects operators to implement "should" statements in industry standards that are invoked by the rule. Operators may choose to implement an alternative approach in meeting the recommendations of invoked standards. If this approach is taken, program requirements for the alternative approach must exist in IM Program documents and records must be generated by the alternative approach. The IM Program documents must also technically justify that the alternative approach provides an equivalent level of protection. If an operator chooses not to implement a "should" statement in an invoked standard, a sound technical basis for why it has not been implemented must be documented in the IM Program documents.